TIC/NSA Required Health Plan Reporting

As part of Evolution Healthcare’s continued dedication to helping our clients comply with the Transparency in Coverage and No Surprises Act requirements, we wanted to let you know how we’ll be supporting your plan’s compliance with Section 204.

Section 204 of the CAA

Section 204 of Division BB, Title II (Section 204) of the Consolidated Appropriations Act, 2021 (CAA) requires the reporting and collection of certain health plan data to the Department of Health and Human Services, the Department of Labor, and the Department of the Treasury. The Centers for Medicare & Medicaid Services (CMS) is collecting Section 204 data on behalf of the departments.

Health insurers offering group coverage, health insurers offering individual coverage, fully insured and self-funded health plans (grandfathered and non-grandfathered) must submit this data.

The deadline for the 2020 and 2021 reference years was deferred to December 27, 2022. The deadline for subsequent reference years is June 1st of the calendar year immediately following the reference year.

Evolution’s Support

Evolution will submit the following data on your behalf:

  • P2 Group health plan list
  • D1 Premium and Life-Years
  • D2 Spending by Category

PBM Reporting Expectations

It is important that you and your brokers ensure your PBMs will be reporting and filing the required data on behalf of your plans. PBMs should be expected to submit the following data on your behalf:

  • D3 Top 50 Most Frequent Brand Drugs
  • D4 Top 50 Most Costly Drugs
  • D5 Top 50 Drugs by Spending Increase
  • D6 RX Totals 
  • D7 RX Rebates by Therapeutic Class
  • D8 RX Rebates for the Top 25 Drugs

Please let us know if you have any questions.